McKeel critique of David Allen and NIOSH January 2012 white paper

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Daniel W. McKeel, Jr., M.D.

Critique of the NIOSH January 2012 White Paper

 “Dose Estimates For Betatron Operations,” David Allen DCAS Author

1. General comments on GSI dose reconstruction:

a) The October 2011 and January 2012 Allen white papers about GSI portable and

Betatron sources need to be acknowledged as being the basis for a revised Appendix BB to the

parent Battelle TBD-6000 document. This may be inferred but is not stated explicitly.

b) It should also be acknowledged by NIOSH that the Director of DCAS has stated

unequivocally that these two white papers are not the basis for a revised SEC-00105 evaluation

report. DCAS Director Stuart Hinnefeld has written to the GSI petitioners and has stated

unequivocally that “NIOSH has no plans to revise its evaluation report of SEC-00105.”

c) There is zero urine uranium bioassay monitoring data for any GSI worker for the

covered period of 1953-1966. GSI has repeatedly minimized, we believe incorrectly, the intake

dose potential inside the two GSI Betatron facilities.

d) The new Betatron modeling dosimetry results using the MCNP code in the January

2012 Allen white paper are misleading in that there is no direct comparison with earlier dose

modeling by SC&A using MCNPx code and by NIOSH using Attila code. The early results

disclosed a highly significant, scientifically troubling order of magnitude or greater discrepancy

between the computer models and the limited GSI film badge results. In addition, the NIOSH

and SC&A models disclosed significant differences between them. These early results need to be

reconciled with the new results. How do the NIOSH MCNP results compare to the earlier Attila

code results by NIOSH? Why were the analyses switched from Attila to MCNP?

e) Mr. Allen and NIOSH have been repeatedly non-transparent about how certain of

their key dosimetry data came into their possession.

e.1) In particular, co-petitioner McKeel first discovered the presence of Landauer

GSI film badge data to NIOSH 13 months before NIOSH obtained the complete data set. McKeel

made the initial contact that led to this important revelation. This was acknowledged in part by

Mr. Allen in an open meeting in Collinsville, IL in 2006. However, the fact has not been

acknowledged in NIOSH technical reports, including the January 2012 paper being critiqued

here.

e.2) Also, co-petitioner Dan McKeel, not NIOSH, filed the FOIA request that led

to the release of NRC FOIA 2010-0012 documents on the NRC website. When McKeel provided

these data to NIOSH a few weeks after obtaining 1,016 pages of GSI by-product materials

licensing information, he explicitly provided the following language as to how these documents

should be attributed. This reasonable request has been totally ignored by NIOSH. Co-petitioner

McKeel believes NRC decided to release these documents because McKeel provided them with

a compelling set of answers to eight questions that must be answered to have NRC waiver fee

waivers. As a result, McKeel believes, NRC released the 1,016 pages—unredacted—without

charging him a fee. In addition, NRC voluntarily provided McKeel an unredacted Index of all

these FOIA documents, listing 37 different sets of documents that comprised the whole. McKeel

provided this Index to NIOSH, where it was and is posted in a heavily redacted form. NIOSH

has never provided a valid explanation why they heavily redacted the unredacted NRC Index

given to McKeel and posted later on the NRC website, including names of many deceased

persons that are not subject to protection by the Privacy Act of 1974.
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e.3) Co-petitioner Dan McKeel and site expert John Ramspott together

interviewed Jack Scheutz, an NIOSH contractee, more extensively person-to-person and before

NIOSH interviewed Mr. Scheutz. NIOSH has been informed by co-petitioner McKeel that Mr.

Scheutz said that Allis-Chalmers, for whom he worked and which was the company that installed

the GSI Old Betatron, “always” conducted a complete and comprehensive radiation dosimetry

of all Betatrons facilities they installed. Mr. Scheutz also told McKeel and Ramspott that he

“destroyed those building surveys when he took over the assets of Allis-Chalmers Betatron

operations and began his service business.” However, to our knowledge, NIOSH and DCAS

have made no effort to secure possible copies of these radiation surveys that would, of course, be

immensely relevant to Betatron operations at GSI and other EEOICPA sites such as AllisChalmers itself and Los Alamos that also operated A-C manufactured Betatrons during the

covered period. McKeel challenges the credentials of Mr. Scheutz to be the most definitive

source of data on GSI operations. He was not a physicist, nor was he credentialed as a health

physicist. He was a well trained Allis-Chalmers Betatron technical repair person to our

knowledge. Also, it was clear to McKeel during the direct interview that Mr. Scheutz had a

vested interest in promoting Betatron technology as a safe NDT modality. Therefore his

viewpoint is biased in this way, and this fact needs to be acknowledged in assigning a weight to

Mr. Scheutz’ testimony.

2. Specific dose reconstruction and SEC issues:

A. Issue #1: Exposure data from an 80 Curie cobalt-60 source from the 1968-71 during

the residual contamination period cannot be used to model Betatron exposures during the

1953-1966 covered period. This entire section and analysis should therefore be completely

disregarded and not allowed to be part of a revised Appendix BB, the announced intention of

producing this new technical paper. There is no surviving GSI Betatron x-ray dosimetry data. All

of the logbooks, “shot records,” x-ray check off and analytic reports known to be generated for

the MCW Uranium Division by GSI, uranium ingot shipping manifests and inventory sheets,

have been lost, destroyed or misplaced (and therefore not found) by DOE/NARA. The

petitioners have repeatedly suggested that NIOSH seek these records among MCW reports, yet

this data capture effort has never been made by ORAU as part of the EEOICPA funded Data

Capture program to our knowledge.

B. Issue #2: External and internal photon doses, beta skin doses, and neutron data

derived from calculated 1963-66 photon-to-neutron ratios cannot reliably be back

extrapolated from the 1953-66 early years of the GSI covered period. These p-to-n rations

were based on modeled photon doses rather than real doses. There is no actual (measured)

neutron data from the two GSI Betatrons. Other SECs such as the first Rocky Flats SEC were

approved because p-to-n partial dosimetry data was not thought to be sufficiently accurate to

define dose. Ther eis no convincing NIOSH neutron data at GSI, even though it has been shown

by the petitioners that the ~15% of the output beam of 24-25 Mev Allis-Chalmers Betatrons of

the same type as used at GSI was neutrons.

C. Issue #3: NIOSH and David Allen have mischaracterized the uranium source term

at GSI in at least 4 important ways: [Note: The term “Mallinckrodt” refers to the Uranium

Division of Mallinckrodt Chemical Works-Destrehan Street and the Uranium Division feed
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materials DOE plant operations at the Weldon Spring Feed Materials Plant in St. Charles

County].

[1] The GSI petitioners and site experts have produced unchallengeable data from

Mallinckrodt documents that David Allen’s analysis of GSI nondestructive testing of

Mallinckrodt uranium during 1953-66 is incorrect in at least three aspects:

[1a] MCW and Weldon Spring sent 2-step uranium ingots and 1-step uranium

dingots to GSI for nondestructive radiographic testing (“X-ray NDT”) using the two plant

Betatrons. These uranium forms were in addition to the uranium slices that David Allen rerred to

in the January 2012 white paper.

[1b] The purpose of X-ray NDT at GSI on Mallinckrodt uranium was not only, or

even primarily, to uncover structural defects as David Allen claims in the January 2012 white

paper. Rather, the major purpose was to define the interface between the outer magnesium

“slag” or “crust” that coated each ingot or dingot after it emerged from the “bomb” (metal

vessel) in which the ingot or dingot was formed. MCW needed this precise slag/pure uranium

interface location information in order to guide the lathes that shaved away the mg-fluoride crust

to expose the pure uranium surface of the ingot or dingot. The petitioners and Mr. Ramspott have

described and documented this process by documents and photographs. It is really unfathomable

why this basic fact is ignored repeatedly by NIOSH and Mr. Allen. Obviously, an entire intact

ingot or dingot would have to be examined by x-ray NDT at GSI. The goal could be, and we

contend was, reached by doing glancing shots around the ingot/dingot. The crust was only a few

inches thick, and the underlying interface with the pure uranium was readily imaged by the

powerful Betatron x-ray beam. GSI Betatron operator Ed Brawley clearly described this process

on the record.

[1c] The heavy uranium ingots, dingots (and possibly the “Betatron slices”) were

transported from Mallinckrodt-Destrehan Street or Weldon Spring Feed Materials Plant to GSI

across the Mississippi by truck. Those trucks had to be unloaded when they reached GSI. Heavy

steel castings and the uranium, according to worker testimony, were transported within the GSI

campus and building complex by rail. Railroad engines were used to bring the castings and

uranium into the Old Betatron Building. Petitioners and Mr. Ramspott have provided maps of the

route of these GSI railroad tracks. Railroad tracks entered both Betatron facilities. There were no

docks for trucks in either Betatron building. Castings and the uranium ingots and dingots, each

weighing perhaps 3,000 pounds, were transported through several GSI buildings and through

building 10 by electric rail engine on the way to the tunnel entry to the New Betatron facility that

adjoined and was connected to Building 10. NIOSH has failed to calculate exposures to the many

unbadged workers who handled the uranium during the transport loading and unloading and

transport operations described above. These real doses have to be calculated and be made part of

the assigned external and internal dose for uranium by unbadged and badged workers. This has

not yet been done despite repeated urging by the petitioners, site experts and workers to do so.

[1d] David Allen in the January 2012 white paper incorrectly states several facts

to support his rationale for using the New Betatron doses, based on film badge readings of the

operators, as bounding for the Old Betatron x-ray unit for the entire covered period of 1953-

1966. This is not just a dose reconstruction issue; it is also a fundamental SEC issue. Mr. Allen is

incorrect in stating that the peak uranium volume for Betatron NDT examinations was during the

last three years (1964-1966) of the GSI covered period when film badge data were available. In

fact, as has been documented on the record previously by analyzing MCW-AEC purchase orders

issued to GSI, the peak year was 1962. Thereafter, uranium shipments took a sharp decline in
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numbers. The preponderance of worker testimony evidence is that most of the AEC MCW

uranium NDT work was performed during the entire covered period was done in the New

Betatron building, not the New Betatron building as Mr. Allen indicates. It is true that overall

Betatron activity likely increased with the addition of the second unit from Eddystone in 1963.

However, I would point out again, that NIOSH has zero shot records or log books or shipping

manifest, or steel materials inventory records, that would prove this is the case. The written

records of GSI operations during the covered period are practically nonexistent. So, Mr. Allen’s

“facts” are mostly educated suppositions (guesses) and are definitely not established facts.

D. Issue #4: David Allen has mischaracterized the Betatron NDT work on MCW

uranium products in other significant ways in the January 2012 white paper.

a) Workers testify that a large majority of the GSI NDT examinations of MCW uranium

took place in the Old Betatron building. That must be the case, because the New Betatron

machine and building were not in place at GSI until 1963. Nevertheless, Mr. Allen implies that

the model to be used for uranium doses at GSI should be based on exposures in the New

Betatron building. This analysis is therefore by definition false and misleading, and the

underlying assumption that both Betatrons and their facilities are equivalent is incorrect. Based

on OCAS-IG-003 dose from all radiation source terms at a facility during the covered period

must be determined. Such is not the case for GSI in any NIOSH technical report, including David

Allen’s January 2012 white paper under discussion here.

b) Mr. Allen fails to note that no MCW-AEC purchase orders to GSI for NDT

examinations are available for the years 1953-1968 of the covered period.

c) During the DOE cleanup of the GSI Betatron facilities in 1992, ORNL found residual

uranium contamination only in the Old Betatron Building. Mr. Allen’s January 2012 white paper

ignores this well documented fact.

E. Issue #5: Very limited, non-representative film badge data from 89 men doing a

single job (Betatron operator/radiographer) of a workforce of 3000 to 4000 men and

women for 3/13ths of the covered period in years is in no way representative of the entire

work force. As such it cannot be used to bound doses for anyone except the 89 persons with

data. With respect to the rest of the GSI workforce, there is absolutely no film badge or urine

bioassay for uranium data, or ambient air or “dust study” data for any portion of the covered

period.

Petitioners contend there is no compelling scientific rationale for being able to back

extrapolate the film badge data to other workers and to the first ten years of the covered period.

Petitioners further challenge the validity of NIOSH accepting SC&A evidence from Landauer

that the highest film badge readings at GSI were retracted. Such retractions of GSI film badge

data were not brought up by Landauer representatives Chris Passmore and Emily Quirke first

discussed the GSI film badge data with McKeel in 2006 thirteen months before either NIOSH or

SC&A were even aware of the existence of this information. In fact, Ms. Quirke went out of her

way to highlight the highest reading of 30 REM, and to point out that this was received in one

quarter. That quarter coincided with a high exposure accidental exposure known to have

occurred with this individual (Peterson) as supported by detailed affidavits from coworkers who

were eye witnesses to these events. There is evidence that the GSI film badge “retraction” letter

signatures by individuals with the highest FB readings were forged by GSI supervisors. NIOSH

has refused to supply petitioners with copies of the unredacted letters citing the Privacy Act of
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1974. However, the affected workers are and were both deceased and therefore were not

protected by the PA of 1974 at the time these requests for unredacted copies were made by the

petitioners. There is no polite term for this action by NIOSH: the best case scenario is that it is

censorship; the worst case scenario is that the denial of unredacted letters constitutes obstruction

of legal due process.

F. Issue #6: The petitioners challenge David Allen’s use and job characterization of a

theoretical Layout man as the prototype for all workers at GSI apart from the Betatron

radiographers. In Allen’s construct in the January 2012 white paper, all workers other than

Betatron operators and assistant operators will be assigned one dose, and everyone else will be

assigned another dose calculated for the prototypical Layout worker. As a comment, confining

the Betatron operator dose only to people who worked most of the time in the Betatron buildings

is unfair. Why? Because many persons such as guards, electricians (prominently as workers have

testified), inspectors and certain other workers routinely entered and left the Betatron buildings

and could have accordingly received extra dose compared to a Layout worker who never entered

the Betatron facilities.

First, there is zero (no) film badge or urine uranium bioassay intake data or Radium-226

or cobalt-60 or industrial x-ray machine dosimetry monitoring data for any GSI workers except

the Betatron and isotope radiographers.

Second, there is no way to construct a valid co-worker model for GSI “general” workers

such as Layout workers because, as admitted first by OCAS Director Larry Elliott, “GSI is a

unique site.”

Third, there is no breakdown of Layout workers versus the general workforce at GSI with

respect to gender. There is recent epidemiologic information form the general radiation literature

that for certain types of cancers women respond differently than men to radiation exposure

[REF]. So, Layout worker may not be representative of the entire GSI workforce for gender.

Fourth, David Allen cites no evidence that GSI Layout workers actually received more

dose than GSI welders, burners and grinders, for example.

Fifth, Mr. Allen misrepresents what a Layout worker actually does. He ignores the fact,

established by petitioner and site expert photographs, that some steel castings required up to 400

(four hundred) separate shots. Allen’s analysis indicates that almost all shots were either 15

minutes or 60 minutes.

Sixth, workers in building 10 near the break area and railroad tunnel entry to the New

Betatron building, and the 300 workers there is testimony worked near the inner roofless

building 6 radiography facility, probably received higher external doses compared to Layout

personnel in other parts of the factory. NIOSH cannot identify which particular workers were

the included in the “building 10” and the “building 6” GSI worker cohorts. This is an SEC issue

as well as a dose reconstruction issue.

Seventh and most importantly, the Allen analysis does not compare how the external

photon, neutron and beta doses calculated in the January 2012 white paper compare to dose

assigned to workers other than the Betatron operators in Appendix BB, Rev 0. This is a major

and crucial omission, since this white paper will form the basis for a revised Appendix BB Rev

1 according to DCAS Director Stuart Hinnefeld. Such an analysis will be further important

guidance for health physicists who will be charged with performing second (repeat) dose

reconstructions for GSI claims whose claims have been denied. It is certain that many such

situations will arise.
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3. Issues that bear on validity and veracity of GSI dosimetry information:

Co-petitioner McKeel offered the following comments on both of the following issues to

the full ABRWH on February 28, 2012 at its regular meeting in Oakland, California.

G. Issue 8. The red steel roll up ribbon doors in the Old and New Betatron facilities

during the covered period. McKeel’s comments on 2/28/12 to the full Board were as follows:

FINDING #1. The Betatron exit tunnel doors were NOT

double leaf and lead shielded during the covered

period of 1953-1966 as is stated in the January 2012

Betatron paper. We have photographic and affidavit

proof that the double leaf doors were installed in

1971 or 1972 after the covered period had ended.

Betatron workers to a man had always stated that the

tunnel exit doors on both the Old and New Betatron

buildings were a “steel red ribbon type roll up door.”

NIOSH evidence: On pages 2, 3 and 4 of the 30 page

January 2012 white paper Mr. Allen showed drawings of

the Betatron buildings from the 1992 FUSRAP cleanup

and the GSI cobalt AEC license renewal application.

The drawing had originated in the GSI 80 Curie AEC

license application in 1968, two years after the

covered period had ended. The text noted the doors

were “double leaf with lead shielding.” Similar

“double leaf doors” minus the reference to being lead

shielded were described and shown in drawings in the

ORNL DOE cleanup report for the GSI Betatron buildings

in 1992. The page 4 drawing indicates the nearest

building is 1000 feet away.

McKeel-Ramspott evidence: There is both old and recent

direct worker confirmation that in the 1963-66 time

period the Old and New Betatron tunnel exits were

“red, steel, roll up ribbon doors” that could not be

retrofitted with lead shielding. Ramspott and McKeel

have their own Old and New Betatron photographs, and

ones from the Department of Energy cleanup in 1992

that they obtained, that indeed show the exit doors

have double leaf doors with vertical strips on the

lower panel. These doors bear no resemblance to the

red ribbon roll up door described by the workers at

the end of the covered period. However, in September

2006 Dan McKeel had a photograph of the exact type of

red, steel, roll up ribbon door that enclosed the

building 10 entry to the break area that was an

extension of the New Betatron Building tunnel. AEC

documents said the break area tunnel at the entry to

Building 10 was bounded by a chain mesh. Workers

testified that in 1963-66 the break area entry to

building 10 was wide open, not enclosed at all.
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These observations lead to several important

conclusions:

 (Conclusion 1) It is incorrect to reconstruct doses

for the covered period based on the assumption there

was a double leaf lead shielded door to stop limit the

dose to workers in building 10 and in the New Betatron

break area. This section of the second Allen white

paper should be retracted and doses redone based on a

roll up unshielded steel door at the end of the two

Betatron tunnels.

 Conclusion ( 2) The January 2012 Allen white paper

also contains the incorrect statement that the nearest

building from the Old Betatron building during the

covered period was 1000 feet away. In fact, to the

contrary, the Old and New Betatron buildings were only

300 feet apart. The outside of the Old Betatron

Building contained a sign, that McKeel photographed in

2006, which said “Do Not Approach This Building Within

100 Feet.” We hold this sign meant that radiologic

surveys must have established a significant radiation

danger field around the Old Betatron building. We can

assume a similar danger zone also surrounded the New

Betatron facility. Those 100 foot radius zones would

clearly involve persons in building 10 and in the

space between the two Betatron buildings. This was a

very busy area that many unbadged workers also used to

by-pass walking through the foundry. Casting “flasks”

filled the area that had to be placed there. Many

persons parked within 100 feet of the New Betatron

facility as proven by photographs from the GSI

magazine. These between Betatron doses have not been

modeled or measured accurately by NIOSH, nor have they

been recognized or modeled by SC&A.

 (Conclusion 3. Once again NIOSH and SC&A have given

insufficient weight to worker testimony about the true

nature of the Betatron doors and shielding in the

covered period. Instead, the paper uses information

about the Betatron facilities from the residual period

that has no relevance to the covered period situation.

On the next page are photographs of the double leaf doors placed, the petitioners and site

experts believe, in 1968, after the covered period which ended in 1966. Lead shielding was not

observed by any living Betatron workers on the double leaf doors at the Betatron exit tunnels.

The doors that should have been modeled in the Allen January 2012 white paper are also shown

on the next page as “red, steel, roll up type ribbon doors” that all GSI workers agree closed off

the rail track tunnels to the two Betatron facilities during the covered period. The building 10

door shown blocked the entry to the New Betatron tunnel in 2006, a place the workers say was

open during the covered period, and DOE 1992 cleanup documents say had a wire mesh closure.
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Legend. The double leaf ribbed door at the end of the

Old Betatron Building railroad track exit on a site

visit photographed by Dan McKeel on 9-26-2006. It is

believed this type of door replaced the red roll up

steel doors in 1968 when GSI obtained its AEC license

for the 80 Curie Cobalt-60 source as an AEC licensing

requirement.
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Legend. A red ribbon door in GSI building 10 blocks the entry to the

New Betatron break area and tunnel in 2006. This type of door is

identical to the “red, steel roll up ribbon doors” that numerous GSI

workers testify was present at the ends of the GSI Betatron building

railroad track tunnels during the 1963-66 covered period. Photo by

Dan McKeel, GSI SEC-00105 co-petitioner on site visit 9-26-2006.

H. Issue 9. Alteration of the original NRC FOIA 2010-0012 drawing of the 1962 status

of the inner Radiography structure in GSI building 6. McKeel’s comments on 2/28/12 to the

full Board were as follows:

Finding #2. The building 6 radiography facility has

been incorrectly modeled for the period 1953-1962 when

Radium-226 was being used for nondestructive testing.

This is an SEC issue. In the October 2011 first Allen

GSI white paper on portable sources, on page X is

shown an August 1962 drawing of the building six

roofless radiography facility. SC&A uses the same

drawing in their review. Packet 3 of 37 of the NRC

FOIA 2010-0012 material that Dan McKeel obtained, on

page X, shows the same drawing in which “D. Darr” has

signed the drawings and annotated that the steel

plates and second layer of concrete blocks were “added

in June/July 1962.” Mr. Darr’s name and the date

annotation were omitted both in the SC&A review

drawing and in the GSI 1962 AEC license application

for the 0.5 Curie Co-60 sources.

Scientifically, this is a very troubling omission of

key data, because it confirms worker testimony (Leroy

Dell, Jim Powers) that no such steel plate shielding

was in use prior to 1962 when the same inner structure

was used with radium-226 sources and the “fishpole

technique” the AEC banned from use in the early 1960s

throughout the

USA. Workers state that 300 unbadged workers were near

the building 6 radiography facility. This differs from

the Allen-SC&A analysis.

Finding #2 indicates that neither NIOSH nor SC&A

thoroughly reviewed the McKeel NRC FOIA 2010-0012

materials. Lack of a door in the inner radiography

structure before 1962, and walls that were a single

concrete block thick, had been testified to NIOSH and

SC&A by GSI workers previously but was ignored in the

recent Allen white papers. Radium-226 doses in and

surrounding the building 6 radiography facility from

1953 to 1963 of the covered period should be

recalculated or modeled by NIOSH and SC&A. The SEC

issue is that no actual (that is real) radiologic

surveys had been made of this facility prior to 1962

when there was less steel and concrete shielding.

Again, the Darr June/July 1962 annotations proof the

changes were applied to an existing facility and

further confirm worker testimony to that effect.
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Another overall conclusion that applies to both

Findings is that GSI license applications to the AEC

cannot be trusted without confirmation by readily

obtainable worker testimony. This company was clearly

self serving to the detriment of workers. It is clear

to us that GSI. The D. Darr June/July 1962 annotations

should have been incorporated into the 1962 GSI

cobalt-60 license application to the AEC, but

apparently someone removed them. This removal of key

data casts doubt on the validity of the entire Wilfred

Konneker and Nuclear Consultants Corporation

radiologic survey and input to the GSI license

application. Correct scientific data appears to have

been deliberately manipulated according to the written

record.

GSI petitioners, site experts and former workers

and claimants that the TBD-6000 work group carefully

consider these new findings when making a final

recommendation on GSI SEC-00150 to the full Board.

Legend added: D. Darr signature clear with annotation

“Shows Additional Shielding Added During June-July 1962.”
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The NRC FOIA 2010-0012 material from which the above drawing was taken was

available to both NIOSH (David Allen) and to SC&A (Robert Anigstein) when their respective

reports were written in 2010 and 2012. They should have been aware of this drawing.

This new understanding of the different physical characteristics and shielding in the

building 6 Radiography structure pre- and post June and July 1962 and the AEC license

application radiologic survey of August 1, 1962 by Nuclear Consultants Corporation has another

important implication. SC&A reported MCNP modeling of radium-226 when part of this work

was done inside the building 6 Radiography facility and part was done in the rest of the GSI

building complex (see Leroy Dell and James Powers interviews) as follows:

Effective Date:

10/20/2011 Revision No. 0 – Draft Document Description: White Paper:

Update on the Use of Sealed Radioactive Sources at GSI Page No. Page

19 of 25

Appendix B MCNP SIMULATIONS OF EXPOSURES FROM 226RA

IN NO. 6 BUILDING

Prepared by Robert Anigstein and Richard Olsher S. Cohen & Associates

• We simulated the exposures and dose rates from 226Ra in the

radiographic facility in No. 6 Building at GSI using the MCNP5 radiation

transport code. The model of the radiographic room was based on a

sketch in the GSI application for an AEC byproduct material license (NRC

2009e, p. 31), which is replicated in Figure 4.

However, all or essentially all of the radium-226 NDT work at GSI was done pre-1962

when, we now know through D. Darr’s annotation, all of the shielding, the steel plates and added

concrete block wall thickness, allegedly was added to the building 6 radiography structure in

June and July 1962. So SC&A incorrectly modeled the better shielded post July 1962 situation

rather than the correct situation that prevailed after mid-1962. The petitioners therefore assert

that all radium-226 modeling reported by SC&A is thus substantially incorrect, and to

preserve claimant favorability the SC&A analysis should be retracted and redone to reflect the

higher doses the radium-226 fishpole technique operators would have undoubtedly been

subjected to before July 1962 of the covered period when the radium-226 NDT work was

actually performed. NIOSH needs to address the lack of observational evidence that the steel

plate shields were actually in place at a specific date.

I must reiterate the fact that an extra thickness of concrete blocks was added in June and

July 1962 has been challenged by a GSI worker (JTD), who told the petitioner he climbed up to
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the top of the building 6 radiography wall in 1963 and observed the wall was “only one block

thick.” NIOSH needs to produce observational data to confirm that extra concrete was actually

added to make the walls 24 inches thick in the building 6 Radiographic facility.

I. Issue #10. The peak period for uranium NDT work at GSI was not 1964-66 (detailed

information in Appendix A). Related to D Issue #4 on page 4, the January 2012 GSI white paper

perpetuates another error first promulgated by the former OCAS Director Larry J. Elliott. That is,

that the peak uranium radiographic NDT operations on MCW-AEC uranium took place during

1964-66 when film badge data is available on 89 Betatron and isotope radiographers. In fact, as

shown from Rev 0 of Appendix BB, section 2.2, there was a dramatic decline in MCW uranium

purchase orders to GSI for uranium NDT work from 1961 to 1966 amounting to 97 percent!

J. Issue #11. The nearest distance to another building from the Betatrons was not 1000

feet (support information in Appendix B) as was claimed in the 1962 GSI AEC license

application to obtain cobalt-60 sources. Mr. Ramspott and several GSI Betatron operators

refute the erroneous statement on the GSI 1962 cobalt license examination that the nearest

building was 1000 feet away from the Betatrons. That is decidedly not true. Measurements by

John Ramspott shown in Appendix B, estimates by GSI workers, and SC&A data all indicate the

two Betatron facilities were within 300 to 312 feet of one another. The inter-building area bore

heavy human traffic as has been mentioned.

As I have noted, the Old Betatron Building contained a sign that read “Do not approach

within 100 feet of this building.” Dan McKeel photographed this faded sign in 2006 and it was

shown to be present in 1992 photographs of the same facility that John Ramspott obtained from

DOE made during the cleanup campaign.

GSI should not have made this false statement to the AEC, and Mr. Allen should have

disavowed the factual basis for the assertion in his January 2012 white paper.

K. Issue #12. David Allen incorrectly describes “head flipping” of the Betatron. The

following entry occurs on page 7 of 30 of the January 2012 David Allen GSI white paper:
McKeel critique of David Allen and NIOSH January 2012 white paper

- 13 -

Allis-Chalmers promotional literature states that 45 degree rotation of the camera head in

either direction is a normal feature of their Betatron. See the large casting on a flatbed RR car

image on page 14, for example. The Betatron head would have to be rotated 45 degrees in either

direction to image the entire casting using x-ray NDT. The downside is that a shot using this

scenario to the right would send the beam down the long “L” tunnel that contains the railroad

tracks. The thin unshielded roll up ribbon door that closed the Old and New Betatron building

tunnels in the covered period would not have stopped the Betatron beam in this position.

Head-flipping is quite different—cited as being dangerous—and is forbidden as a safe

operational technique to x-ray inspect objects in the opposite direction from the limited normal

movements of the Betatron head. Head flipping has been well described by GSI Betatron

workers. It is troubling that normal and banned operations are being confused at this late stage of

the dose reconstruction program when 94% of GSI dose reconstructions have been completed.
McKeel critique of David Allen and NIOSH January 2012 white paper

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SUMMARY AND CONCLUSIONS:

I decided not to submit a line-by-line rebuttal to the David Allen and NIOSH January

2012 white paper because the “big picture” extensive factual and scientific distortions,

intentional selective citation, lack of proper professional attribution, and inaccuracies assumed

overarching importance when I reviewed this second white paper in an Appendix BB process

that has now dragged on since October 2010 (16 months). This report does a disservice to the
McKeel critique of David Allen and NIOSH January 2012 white paper

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EEOICPA process and is the opposite to the intent of Congress to be claimant favorable in every

way when our elected federal officials established EEOICPA in 2000 to compensate deserving

nuclear weapons workers. This report even being allowed to take a further 15 months to research

and be published is an affront to every GSI claimant and to the petitioners, and to GSI advocates

and experts, and supporters and families of GSI workers and claimants. It is a further affront that

Appendix BB has not been revised since June 2007 when Rev 0 was released.

This summary and conclusions includes information from the October 2010 Allen white

paper that dealt with portable radiation sources at GSI. The two Allen white papers encompasee

all ten new dose reconstruction “models” that were originally outlined by Mr. Hinnefeld in his

initial announcement that NIOSH would undertake these new studies.

My concluding points can be summarized in brief statements as follows:

1. NIOSH has failed to fully comply with its own guidance OCAS-IG-003 that for dose

reconstruction purposes all radiation sources at a facility during the covered period must be

calculated with sufficient accuracy.

2. NIOSH in the January 2012 Allen white paper improperly cites cobalt-60 dosimetry

obtained outside of the covered period to characterize Betatron worker doses during the covered

period. In the October 2010 Allen white paper on portable GSI sources, NIOSH challenged and

denied that an 80 Curie cobalt-60 source was in use at GSI before 1968. The covered period

ended in 1966. NIOSH cannot have it both ways.

3. Further, with respect to point #2, the radiation characteristics (energy spectrum,

directional vectors, neutron content, and extent of the radiation fields) differ completely from

that of the Betatrons.

4. The radiation patterns cannot be assumed to be comparable or lower for the Old

compared to the New Betatron buildings as David Allen does in the January 2012 white paper.

5. The two most recent Allen white papers fail to cross correlate the new doses

calculated for Betatron workers and layout (rest of the GSI work force) workers with the two

dose levels assigned to Betatron and other workers in Appendix BB. The methods and computer

codes were quite different. This will be key for calculating doses in reopened denied cases (so

called “reworks”).

6. In the January 2012 second Allen white paper there is no cross comparison between

the new NIOSH dosimetry calculations for the Betatron using MCNP and the doses modeled
McKeel critique of David Allen and NIOSH January 2012 white paper

- 16 -

previous by SC&A using MCNP and NIOSH using Attila. Why NIOSH switched computer

modeling code is not justified in Allen January 2101. Dr. Anigstein from SC&A has commented

that different software versions of MCNP give different results. Mr. Allen again overlooks these

important scientific points. It appears that Mr. Allen is assigning Betatron workers an overall

dose that is approximately 75% of the dose SC&A assigned to them previously based on SC&A

MCNP modeling results. These lower doses assigned to Betatron workers in part may reflect the

incorrect assumptions that lead shielded doors covered the Betatron shooting area exits. We have

shown these assumptions were false.

7. Both NIOSH/DCAS in Allen January 2012 and SC&A (in their review of Allen

October 2010) used drawings from the GSI 1962 cobalt-60 license application to AEC that were

altered in significant ways compared to the original drawings from two months earlier where “D.

Darr” annotated the steel plate shields and the double concrete walls were added only 1 to 2

months earlier in June and July 1962. There is meager evidence that the steel radiation shields

were added. One former worker says yes and another says no. There is no support for the

proposition, that is no worker affidavit confirmation, that a second layer of concrete blocks was

ever added to the walls on the inner Radiography structure to Building 6.

8. Related to point #6, NIOSH needs to calculate separate doses for radiographers using

the radium-226 sources with the fishpole technique before 1962 (when no shielding was in pace,

a single block wall existed and possibly there was no door) and after 1962 to 1966. Workers

testified that both Ra-226 and 0.5 Curie cobalt-60 sources were used for a short while during

1962 and then the ra-226 sources were abandoned as mandated by the AEC for safety reasons.

Mr. Allen fails to acknowledge these nuanced points, nor have the necessary dose calculations

been carried out.

9. A former GSI Betatron operator who was very familiar with the two Betatron facility

control rooms disputes there was a separate “control room badge” as Allen reports the Landauer

film badge data indicates. This person (JTD) is well known to the Board and is willing to sign an

affidavit to that effect. The petitioners believe and assert the control room badge data cannot

therefore be validated or trusted, and that the 114 readings do not necessarily represent the true

dosimetry readings in the two control rooms. SC&A modeling, in fact. showed the highest levels

of radiation occurred in the control room that was supposed to be protecting the workers. The

Betatron control rooms both had thin metal doors that would not impede the high Mev photons
McKeel critique of David Allen and NIOSH January 2012 white paper

- 17 -

and x-rays that were prevalent during Betatron shots. Photos of these thin metal doors have been

provided previously to NIOSH, the Board and SC&A by Mr. Ramspott and the petitioners.

10. Although the reasoning is obtuse and poorly described, using tortured scientific logic

in my opinion, Mr. Allen improperly attempts to “explain away” Jack Scheutz’ direct

measurement of residual Betatron activity for 15 minutes after the camera is turned off. The

petitioners have produced several papers (many more being available) that clearly show that

many internal components of all high energy particle accelerators become ectivated with

prolonged duty cycles, and that some of these activation products have half lives longer than

15 minutes. To the petitioners, therefore, the Scheutz observation is both expected and readily

explainable. The appearance is that NIOSH wishes to explain away the residual radioactivity

because it is “inconvenient” and results in a higher overall dose to Betatron operators. Good

science and the intent of Congress was that workers should be compensated and that such

adversarial tactics have no valid place in implementing the dose reconstruction program under

EEOICPA 2000.

11. After spending 16 months developing new dose reconstruction models and methods

for ascertaining external and internal doses to all GSI workers, the two main work products that

NIOSH has produced, the October 2010 and January 2012 David Allen white papers, are full of

bad assumptions, use data from the residual period that cannot apply to the covered period, and

incorrectly model Betatron doses and x-ray particle accelerators that produce a very tight,

narrow, and highly directional beam that has to be widened through a beam flattener (read

spreader), by using as a source a Cobalt-60 gamma source beam that is not collimated and

radiates as a sphere in all directions. NIOSH has claimed an 80 Ci C-60 source was not at GSI

during the covered period 1953-66; GSI workers have claimed otherwise.

The overall result of these new studies and new dose modeling results is a predictable

lowering of the overall dose attributed to Betatron operators and assistant operators. By

incorrectly assuming the presence of lead (Betatron tunnel exit doors) and steel and concrete

shielding (inside steel plates, outside extra concrete added to walls of the 6 building Radiography

facility) that was not there during the covered period when radium-226 was being employed,

NIOSH has lowered the dose that will be assigned to workers. Further, dose lowering has been

achieved by more rather than less reliance on film badge data that, in the petitioner’s view, have

been manipulated and mishandled by both NIOSH and SC&A. Vital information about the
McKeel critique of David Allen and NIOSH January 2012 white paper

- 18 -

highest film badge doses have been deliberately and improperly withheld from the petitioners

and knowledgeable workers and site experts. The worker with the second highest film badge

dosimetry reading at GSI denies he was even informed about having received such a dose. If this

is a true statement, then how could that person have signed a letter addressed to Landauer

retracting his high film badge reading? We assert this did not happen. It is clear the true facts

from this episode have not been fully disclosed by NIOSH or by SC&A to the Board.

Such considerations engender a very disturbing reaction to the last two David Allen

white papers. This reviewer and long time GSI co-SEC-00150 co-petitioner has no choice but to

conclude that NIOSH is attempting to limit the dose to all GSI workers. I will leave assigning

motive to others. However, I must observe the overall effect is strongly adversarial to the true

intent of EEOICPA, and is definitely harmful to the financial well being of affected workers by

diminishing their chances to be fairly compensated based on scientifically sound, well

researched, and well described dose reconstruction methodology and practices.

Reference: Letter from Senator Barack Obama and Representative Henry A. Waxman to Stephen

L. Johnson Administrator, U.S. Environmental Protection Agency May 30, 2008. (URL:

http://www.ieer.org/sdafiles/16-1/referenceman-letters.pdf). The cited EPA letter states the

following: “At issue now is whether separate male and female risk coefficients should be

published for the general population, given the approximate two-fold difference in risk per unit

dose estimated in BEIR VII.”

Appendix A and B attached ________________________________________

Daniel W. McKeel, Jr. 2/27/2012

Respectfully submitted by:

Daniel W. McKeel, Jr., M.D.

GSI SEC-00105 co-petitioner

Founder: Southern Illinois Nuclear Workers (SINEW)

Retired Associate Professor of Pathology and Immunology

Washington University School of Medicine in St. Louis, MO

Phone: (573) 323-8897

Fax: (573) 323-0043

E-mail: danmckeel2@aol.com

US Mail: P.O. Box 15, Van Buren, MO 63965-0015
Appendix A: McKeel critique of Allen2 January 2012 GSI white paper

- 1 -

Uranium NDT Hours at GSI: Cost Allocations by Year According to

Purchase Orders Listed in TBD-6000 Appendix BB Rev 0 dated 6/25/07

- Data from John Ramspott to Dan McKeel (e-mail dated 1-18-09)

E-mail subject line: Fwd: "Right from NIOSH's Report" URANIUM AT GSI

Body of e-mail message:

Begin forwarded message:

From: John Ramspott <jwramspott@sbcglobal.net>

Date: January 18, 2009 10:11:08 AM CST

To: Dan McKeel <danmckeel2@aol.com>

Cc: John Ramspott <jwramspott@sbcglobal.net>

Subject: "Right from NIOSH's Report", then they ignore this most important fact, Re: The

Badges for 1964-66 !

Re:

John,

Thank you for all of the recent info from Dow and GSI. Please send me the proof that shows 400

hrs of AEC uranium work at GSI in 1962 compared with only 28 hrs in 1964, the year LJE says

was the peak. This is most important to get in the record ASAP as clearly as possible to refute

NIOSH's attempt to use 1964 badge data to bound the entire 1953-1966 AEC period at GSI.

Thanks! -- Dan 1/18/09

As requested !

Effective Date: 6/25/2007 Revision No. 0 Page 2 of 12 (below) "Right from NIOSH's Report",

then they ignore this most important fact !

Office of Compensation Analysis and

Document Number: Battelle-TBD-6000

Support Appendix BB

Effective Date: 6/25/2007 Revision No. 0 Page 2 of 12

General Steel Industries, Inc., at the same address. The ingots were in the form of

cylinders 18 to 20 inches in diameter, approximately 18 inches long, and weighing up to

3000 pounds. The betatron x-ray equipment was Government owned. The uranium to be

x-rayed was owned by the AEC and provided by Mallinckrodt3.

BB.2.2 Frequency of uranium X-rays

General Steel Industries work with uranium was performed under purchase orders with

Mallinckrodt Chemical Works starting in March of 1958. These purchases orders cover

the time period March 1, 1958 through June 30, 19664. These purchase orders indicate

that the work was to “X-ray material as requested by Mallinckrodt...”. They also
Appendix A: McKeel critique of Allen2 January 2012 GSI white paper

- 2 -

contained “Betatron labor charges, including operation and maintenance and all overhead

shall be billed at $16.00 per hour.” The last purchase order covering the period of July 1,

1965 to June 30, 1966 indicated a billing rate of $35.00 per hour. The purchase orders

also indicated that the work was not to exceed a set cost. The first purchase order,

covering the period March 1, 1958 to June 30, 1958 stipulated a monthly limit of $500.

That purchase order was extended to October 31, 1958 and added $1800 to the total limit

(an additional $450 per month). A new purchase order covered the period November 1,

1958 to June 30, 1959 and stipulated a monthly limit of $450 and a total limit of $3600

(equal to $450 per month). The next purchase order covered July 1, 1959 to June 30, 1960

and stipulated a monthly limit of $450 with a total limit of $7200. It should be noted that

the total limit does not add up to 12 months at the monthly limit. This is the only purchase

order with this conflict. Since these are limits and not estimates, the most limiting of the

two values will be used in this appendix which is consistent with purchase orders written

both before and after this one.

From that point on, the purchases orders were written annually covering a period of July 1

to June 30 of the next year. All but the last order stipulated a billing rate of $16 per hour.

The purchase order starting in 1960 stipulated no total limit. Only a monthly limit of $450

per month was specified. After that, only a total limit was specified. These limits were

$7000 for the purchase order starting in 1961, $2000 for the purchase order starting in

1962, and $450 for each of the remaining purchase orders.

From this information, it is possible to determine the maximum hours per year that

General Steel Industries spent on operations, maintenance and overhead associated with xraying uranium for Mallinckrodt Chemical Works. Through June 30, 1961 the limit was

generally $450 per month at $16 per hour or 337.5 hrs per year. The remaining years are

shown below.

July 1, 1961 to June 30, 1962 437.5 hrs/yr (based on a total limit of $7000)

July 1, 1962 to June 30, 1963 125 hrs/yr (based on a total limit of $2000)

July 1, 1963 to June 30, 1965 28 hrs/yr (based on a total limit of $450)

July 1, 1965 to June 30, 1966 13 hrs/yr (based on a total limit of $450 at $35/hr)

These estimated hours are considered the maximum hours that could have been spent xraying uranium. These are considered maximum because the purchase orders set these

costs as a limit. There is no indication how much of the available funds were actually

Ramspott: How can using Radiation badge information from 1964- 1966, if I understand

correctly, be accurate if NIOSH/ Appendix BB. says:

" These estimated hours are considered the maximum hours that could have been spent x-raying

uranium".

"Directly from": Appendix BB.2.2
Appendix A: McKeel critique of Allen2 January 2012 GSI white paper

- 3 -

Dan McKeel comment 2/27/12 -- This exchange shows that NIOSH DCAS/OCAS at two

junctures, under two different Directors, deliberately distorted their own data to establish the

false “fact” that 1964-66 were the peak years for MCW-AEC contracted uranium NDT work at

the GSI AWE site. David Allen repeats and compounds this same misinformation in his January

2012 white paper on Betatron operations that will form the basis for REV 1 of Appendix BB.

By the end of 1966 compared to 1961, uranium radiographic NDT activities had declined from

437.5 hrs in 1961 to just 13 hours in 1966, a whopping 97%! This is an example of NIOSH data

manipulation being used to the severe detriment of GSI claimants. From these data, the GSI

petitioner’s long held view that 1964-66 are non-representative of the covered period from 1953-

1966 for MCW-AEC uranium operations is even more firmly established.
Appendix B: McKeel critique of Allen2 January 2012 GSI white paper

- 1 -

Appendix B: Nearest Building to Betatrons Analysis to Correct Data Presented

in GSI Betatron Operations White Paper dated January 2012

Subject line: Fwd: Betatron Distance information.

E-mail date: Sat. Feb. 25, 2012 10:10 AM

FYI:

SC&A actually noted 76 meters.

GSI appears to have lied on their Application!

Subject: Fwd: Distance information.

From: John Ramspott <jwramspott@sbcglobal.net>

Date: June 27, 2009 5:42:46 PM CDT

To: Dan McKeel <danmckeel2@aol.com>

Subject: Fwd: Distance information.

Dan:

I asked Terry to contact some of the Betatron workers to get their estimation of the distance from

Old and New Betatron Buildings.

Terry sent me their reply (see below)

I wanted to double check my own estimation using my "ruler and meter to feet calculations"

formula.

(This was also based on SC&A's distance calculations)

Results:

Workers- 300 feet.

Ramspott- 312 feet ( aprox. 95m x 3.28 ft. = 311.6 feet )

We "all" pretty much agreed .

My drawing etc. was actually pretty accurate !

[JWR Betatron drawing & measurements inserted here]
Appendix B: McKeel critique of Allen2 January 2012 GSI white paper

- 2 -

Begin forwarded message:

From: "john t. dutko" <tdutko@charter.net>

Date: June 26, 2009 3:20:42 PM CDT

To: "JOHN RAMSPOTT" <jwramspott@sbcglobal.net>

Subject: Re: Distance information.

JOHN--I CONTACTED GEORGE LUBER, JOE POLLO, DON PIPER, AND AS THE CROW

FLYS, WE ESTIMATE THE DISTANCE FROM THE NEW BETATRON TO THE OLD

BETATRON AT AROUND 300 FEET-----JOHN T. DUTKO

-------Original Message-------

From: John Ramspott

Date: 6/26/2009 2:05:37 PM

To: Terry Dutko

Cc: Dan McKeel

Subject: Distance information.

Terry:
Appendix B: McKeel critique of Allen2 January 2012 GSI white paper

- 3 -

Can you check with some of the other GSI Betatron workers and estimate the distance from The

"Old" Betatron Building to the

"New" Betatron Building ?

Please include the worker's names after you contact them.

Thanks,

John

Dan McKeel Comment 2/27/12: I agree completely that the drawing on page 4 of the Allen

DCAS/NIOSH January 2012 GSI Betatron Operations white paper shows that GSI misstated the

true facts about the distance to the nearest building to the New Betatron facility in their AEC

license application, which is the subject of NRC FOIA 2010-0012 that I first obtained. Such

misrepresentation by GSI reinforces the petitioner’s position that GSI was in many instances

prone to deliver favorable but incorrect information to federal and state agencies that regulated

them. This inured to the detriment of former workers and their survivors who are now EEOICPA

claimants. In toto, these misrepresentations of facts by GSI, and their perpetuation by the current

federal agencies and deliberative bodies and governmental commissions that implement the Act,

converge to cause financial harm to GSI claimants in the form of denied compensation under

EEOICPA 2000 as amended. This is true whether or not the factual misrepresentations by GSI

and their perpetuation by others are “accidental” or intended. In addition, of course, the New

Betatron building was less than 100 feet away from the 10 building at GSI that housed many

never badged male and female GSI employees (burners, welders, chippers, etc.).

 Legend. New Betatron to the left, 10 bldg. to

 right at GSI September 2006. Dan McKeel photo.